What information does Convergence obtain and how do we use customer information?
General practices – gathering
Signing up and ordering services. When customers sign up for service, we ask for their name, street address, email address, how they want their listing to appear in phone directories and directory assistance, and contact information. We may ask for date of birth, social security or driver’s license numbers (to confirm identity or determine creditworthiness), billing information including whether bills should be sent by mail or set up for online access, and bank account or credit card information if a customer elects to pay electronically. We may keep some of this information and use it for future marketing purposes even if a customer does not complete an order with us. We also keep notes of contacts we have with our customers.
Recording, reviewing or monitoring of your interactions with Convergence. For quality assurance and training, we sometimes review email correspondence and record or listen to calls made to or from our Customer Care and repair personnel, sales offices, and business account managers. We also save the text of “click to chat” sessions with our online sales and service consultants, and may save screen shots when customers give our repair personnel remote access to their computers for technical support.
Network recording of service usage. We record information about usage of our networks or systems. For example, we may log dates and times and the telephone numbers of calls to and from our customers, especially when the information is necessary for toll billing. Generally, we do not retain any call information for local landline calls. If a customer activates a “call trace” feature, we will record the number of the calling party. And when we are your Internet service provider (ISP), we maintain logs of the total volume of data a user transmits, and the date, time and length of time that a user accessed the Internet through our services, including the user’s IP address at the time.
Information gathered when visiting Convergence websites. When a user visits a Convergence website (such as Convergence.com), we receive information about the user’s operating system and its browser, the site accessed immediately before accessing our website, pages the user goes to within our website and sometimes the website accessed after leaving it. We also get the user’s Internet Protocol (IP) address,* including the city and state of its location. That lets us customize product availability and pricing for that community. We receive most of this information through the normal operation of the web, and generally this information does not identify any specific user. We may also retain information entered by users on our online order pages, even if the customer does not complete an order.
*An IP address is assigned to a user’s browser by the user’s ISP. The IP address identifies users on the Internet by a number, and part of that number usually identifies the user’s city and state. Your IP address stays the same while you’re connected to the Internet, but a new one may get assigned between Internet sessions.
Information obtained when clicking on Convergence ads on other websites. When we place ads on others’ websites, the ad networks we work with provide general information about users who click on our ads, including the types of browsers they use and their city and state. The ad networks we work with may use that information to predict what Convergence ads may be most effective in a location.
Personal information obtained from third parties. Sometimes, we receive information about our customers from other businesses. This happens, for example, when another business sells our services, or when we bundle our services with services from a television or wireless company. It also happens when we bill for a business, such as a long distance company or other type of service provider. We also obtain information about our customers from businesses that gather it from many sources, including the Census Bureau and public records. Finally, we work with companies that provide us email addresses for our customers.
General practices – use
Routine business uses of personal information. We use information that we obtain from customers or generate while providing our services to set up and maintain accounts, provide and repair our services and equipment, respond to customers’ questions and concerns, bill and collect for our services, plan for future development of our network and services, to market our services, and communicate with our customers and others about our services. We also use our customer information, and information we obtain from third parties, to determine our customers’ creditworthiness and predict what new services our customers may want. We do not resell customer information that we buy from third parties.
When Convergence provides voice service
As a provider of local, long distance, and Voice over Internet Protocol (VoIP) services, we use customer information as outlined above under General Practices.
When we provide VoIP service, we rely on our customers to keep their service addresses current by updating their online customer profile when they change locations. In the event of an emergency, we provide this information to 911 service providers so they can help emergency responders find you.
When Convergence is your Internet service provider
As your ISP, we gather and use information as outlined above under General Practices.
Information we obtain when Convergence provides Internet access. We gather and use information generated on our networks to manage them, to plan for future development of our network and services, to market our services, and to keep our services running efficiently. For example, we monitor data to check for viruses, to control spam, to prevent attacks that might disable our services, to ensure that your traffic does not violate your subscriber agreement or our acceptable use policies, and to guard against other inappropriate or illegal activity. This involves looking at the characteristics of our network traffic, such as traffic volumes, beginning and ending points of transmissions, and the types of applications being used to send traffic across our network. We may also gather details from the modem, for example, the number and types of devices connected and the method of connection (Wi-Fi versus wired) to aid in customer troubleshooting and network operations.
Sometimes we need to look into the content of the data (such as the specific websites being visited, files being transmitted, or application being used) for the purposes described above, in circumstances when we are concerned about fraud or harassment, to repair a problem we detect or that a customer contacts us about, or when we are providing the content of broadband traffic to law enforcement which we only do as authorized by law.
Most of the specific information we obtain that is attributable to a user is kept only for a matter of hours or days. We may retain data for longer if, for example, we see patterns in the traffic that give us concerns about potential harm to our network, or if we are doing a specific study on the impact of certain applications used on our networks. We also retain for longer periods logs of the total amounts of data transmitted, and the date, time, and duration of access to the Internet through our services by a user, including the user’s IP address at the time.
We will not look into the content of your email, websites visited or other communications for marketing purposes without first informing you and giving you a choice about whether you want us to do so.
Advertising based on the location where we provide you service. We may let advertisers know whether we provide you Internet access in a geographic area where they want to advertise to web users, and enable them to target ads to you on that basis. You will not see more ads as a result of this service, just ads intended for those in the location where we provide your service. We will not tell them your service address, your physical location, or your web browsing histories, and we will not provide them any information by which they could identify you. In some instances, we may place a cookie on your computer to keep track of what ads have been displayed through this service. If we take part in an advertising service like this, we will provide you information about it at Convergence.com and our other web portals and enable you to choose not to receive location-based advertisements in the future.
Children’s use of Convergence’s Internet services. We understand that children may use our Internet services. We urge you to pay attention to what your children are doing on the Internet and what sites they are visiting. For more information about online safety, please visit OnGuardOnline.gov, the Federal Trade Commission’s resource for Internet safety.
When you visit a Convergence website
We also obtain information about users when they interact with our sites, such as which pages they visit and any ads they click on. We use this information to analyze and manage our sites so we can keep making them better. To improve our visitors’ experiences, we may store preferences or other information they volunteer to personalize service offerings and ads. For example, we may use a stored telephone number and location to show local product availability and pricing.
We also use information gathered from our sites for security purposes, such as to detect unauthorized intrusions, prevent malicious attacks, and help ensure a safe online experience for our customers.
We may also keep information entered by users on our online order pages, even if the customer does not complete an order. We may use this information for marketing purposes.
Obtaining information from children under 13. Unless otherwise indicated, our websites are intended for general audiences and not directed to children. We do not knowingly collect personal information from children under 13. Note that other providers’ web pages are accessible through links on many of our websites, and those providers may have different practices on collecting and using information from children under 13. If you are concerned about those sites, please review them and their privacy policies.
When we advertise on others’ websites
Does Convergence share customer information?
Sharing information within Convergence. Convergence is made up of a number of companies and we share information among them as permitted by law or with your consent. You benefit when we better understand your interests and needs. And knowing more about how our customers use our services and sharing that information among our companies helps us improve our networks, the services we provide, and our Customer Care. It also lets us personalize our interactions with you, including your online experience.
Sharing information with companies who support our services. We share customer information as needed with companies that help us market, sell, provide, plan, bill and collect for, and otherwise support our services. Often when these companies act on our behalf, they refer to themselves as “Convergence.” We also share limited customer information with companies that provide our customers with telephone equipment, Internet services, television offerings, and wireless services that we may sell as part of our service packages. We require these companies to use our information only for the purposes we specify and to keep it safe and confidential.
Providing information when lawfully permitted and necessary. Like other businesses, we may share information: (1) to comply with laws or to respond to lawful demands such as subpoenas or court orders; (2) to assert or defend our legal rights or the rights of our employees, agents, contractors, or customers; (3) to investigate and protect against fraud, harassment, threats to our network, or other types of unlawful activity involving us, other providers we do business with, or our customers; (4) to protect our property, including our networks, or the property or networks of others; or (5) as otherwise permitted by law.
Sharing information when merging, selling or transferring part of our business, or acquiring another business. . If we decide to merge, sell or transfer a part of our business to or with another company, or to acquire part or all of another company, customer information may be shared or transferred as part of the decision process or as a result of the sale. We might also provide customer information to another company if we decide to stop providing a service. This information may be about the characteristics of our business and groups of customers, or it could include information about specific customers.
Providing information when customers ask. Upon customer request and subject to proper authentication, we will disclose account information to third parties. Please see the Customer Care information at the top of this page for the numbers to call.
Caller ID. We disclose customer information through call-identifying products and services like Caller ID. In some instances, you can block that disclosure.
Sharing of Customer Proprietary Network Information (CPNI). CPNI is a subcategory of protected customer information defined by federal law as information about a consumer’s account, including usage and billing of telecommunications services. Those services are offered by providers of traditional local, long distance, and wireless services, as well as providers of Voice over Internet Protocol (VoIP) services to consumers. CPNI includes what services you subscribe to, how you use them, and what you are charged for them. It does not include your name, address, telephone number, or other types of information such as information about your telephone equipment or Internet access services. Communications companies are required to treat CPNI confidentially, and we do. The FCC regulates when and how CPNI can be shared and used.
Sharing of customer information with third parties for their use
Subject to the exceptions described below, we share customer information with third parties for their own use only where the law requires it or customers have consented to it. For the most part, federal law covers the release of information in these circumstances.
Providing information to other carriers and service providers. In certain circumstances, we share customer information with carriers and other service providers, including competing local and long distance companies, VoIP providers, Internet service providers, and billing companies so that they can accurately provide and bill for their services. This exchange of information is often legally required, and is also consistent with industry standards. In some cases the customer whose information is being provided is a customer of both Convergence and the other provider. In other cases, the other provider has told us that it has the customer’s permission to receive the information. And we will also share information with another provider if we suspect fraud, harassment, a threat to their networks, or some other unlawful activity.
For example, companies like Convergence are legally required to provide customer information to long distance and other service providers (or their billing agents) so they can verify orders, be aware of customer moves, get paid for their services and for other similar non-marketing purposes. We are required to provide such information even if the information is not listed or published, and the law limits these companies in their use of the information.
Directory publishers. By law, when Convergence accepts a directory listing for publication, we must provide that listing information to all directory publishers – both our official publisher as well as third-party publishers. When we receive listings from other carriers, they tell us what directories (if any) they want their customer information published in. Once publishers have the listing information, they can use, sort, organize or package the information in any manner they wish: arranged by name or by telephone number, for example, or published in paper directories, electronic directories over the Internet, on CDs, or in any future directory format that may be developed.
We are also required to give directory publishers the names and addresses of customers with non-listed and non-published information. These publishers can use this information only to deliver their directories and for no other purpose.
If you have elected to have your name, address and telephone number published in white pages directories (which means that it will be public information), that information may be used by others for their own marketing or to create marketing lists
Directory assistance providers. The Federal Communications Commission requires carriers to share customer names, addresses, and telephone numbers with directory assistance providers (including names but not telephone numbers of non-published customers). Some of these providers offer Internet or online directory assistance services. The FCC does not allow us to restrict how these providers use the customer information we give them. But we do require companies that buy our directory assistance information to sign a contract agreeing to honor restrictions you have asked for, such as that it not be published, when they use the information for purposes other than directory assistance.
Emergency service providers. Federal law requires us to provide customer names, addresses, and telephone numbers – including information on non-published and non-listed customers – to emergency services providers, including 911 and reverse-911 providers (who notify the public of emergencies). This information is also provided to those responsible for answering 911 calls when they receive such calls.
Credit reporting businesses. We may provide information on customers’ payment histories to credit evaluation or reporting businesses. We may permit those businesses to incorporate that information into their own databases as part of offering their services.
Identity confirmation services. We may also allow companies to match information provided to them by their potential customers with name and address information in our databases to confirm the identity of their potential customers, and the length of their service with us.
California privacy rights. California Civil Code Section 1798.83 entitles California customers to request information concerning whether a business has disclosed personal information to any third parties for the third parties’ direct marketing uses within the previous calendar year. California customers who want more information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us at firstname.lastname@example.org.
Disclosure of information through links from Convergence websites
Our websites contain links to websites of other businesses. We are not responsible for information those sites collect. If you are concerned about the information collected by these other sites, please review their privacy policies.
When other companies advertise on Convergence websites
Sharing of customer information with the government
Responding to lawful process. We may provide customer information to the government in response to a subpoena, warrant or court order. Among the information we might be asked to provide are a customer’s name, address, telephone number, account number, any Internet Protocol or network address that we assigned to the customer, records of service usage (including interactive session times and durations), how long the customer has subscribed to our services (including start date and the types of services used), and the means and source of customer payment (including any credit card or bank account number used to pay for our services). In response to a search warrant or court order, we may be required to disclose to law enforcement agencies the content of and records relating to telephone calls, email messages (including attachments), Internet usage, and data we may store on your behalf if we provide you cloud computing or managed hosting services. We do not provide notice to our customers of law enforcement demands for information. But our usual policy is to provide notice and the opportunity to object when we receive requests related to civil lawsuits whether from the government or private parties.
Voluntary release of information in an emergency. We may provide customer information to the government if we believe in good faith that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure without delay.
Other voluntary releases of information. Under certain conditions, we voluntarily share information with governmental agencies:
• When customers complain about us to federal and state regulatory authorities, we provide pertinent information (including customer information) in response to those complaints, and may provide pertinent information to other governmental bodies inquiring about such complaints, such as state or federal legislative committees.
• We may share information with the government to protect our rights or property, including information indicating that some portion of our network or the network of another provider is or has been subject to a cyber attack.
• Periodically, we compare our customers’ name and address information with the information possessed by the U.S. Postal Service. This lets us mail at reduced rates and helps ensure that our customers get their bills and other information from us more economically and reliably.
• We also share information with federal and state agencies in connection with their programs to fund universal service and other communications assistance programs for low-income or otherwise eligible persons, including persons with disabilities.
Reporting of child pornography. Like other service providers, we are required to report apparent violations of laws concerning child pornography when we have a reasonable belief of facts or circumstances that warrant a report. In those cases, we contact the National Center for Missing and Exploited Children and may also contact law enforcement directly.
What choices do our customers have about information we obtain and how we use it?
Telephone directory treatment. You can choose whether and how your entry appears in Convergence directories and through Convergence directory assistance. You can choose not to have your name and address in these directory services at all or opt for full names or initials, or full or partial addresses.
Product choices. We provide a number of telephone related services that may help you protect your privacy. For more information about these services, please see the Customer Care information at the top of this page for the numbers to call.
Third party marketing. If you have elected to have your name, address and telephone number published in white pages directories (which means that it will be public information), that information may be used by others for their own marketing or to create marketing lists.
Opting out of marketing communications. You can ask not to receive our marketing calls, mail and email. You will still receive bills, email notices that your bill is available if you subscribe to paperless billing and service related contacts and notices from us even if you choose not to receive marketing contacts.
Opting out of other communications. You may receive repair, billing and order status notifications from us via text or email messages. You may choose not to receive these messages by following the “unsubscribe” instructions in the email message, replying to the text message with “stop” or please see the Customer Care information at the top of this page for the numbers to call.
Choices regarding directory listings
You can choose not to be published in our directories or listed in our directory assistance service. A non-published status means that a number is unavailable in both places, while a non-listed status means that name and number are not printed in directories but are available through directory assistance. To make one of these choices (for which there is usually a fee), please see the Customer Care information at the top of this page for the numbers to call.
Please note that we are required to give non-published and non-listed customer names and addresses to directory publishers for directory deliveries and to directory assistance providers. But we mark the information so that they know our customers’ privacy choices and by contract we require them to follow those preferences.
Choices regarding marketing contacts
Telephone. Federal Do Not Call laws allow you to place residential landline and wireless phone numbers on the National Do Not Call Registry to prevent telemarketing calls to those numbers. If you would like to add your numbers to this list, you may do so by visiting www.donotcall.gov.
Please note that being on a federal or state Do Not Call list will not keep customers from getting our marketing calls because we have an established business relationship with our customers.
If you do not want to receive our direct mail marketing, you must expressly tell us by contacting Customer Care located at the top this page. We will stop sending you direct mail marketing for two years from the date of your request.
Email marketing. To stop receiving commercial emails from us, follow the “unsubscribe” instructions on the email message, or call us. Please see the Customer Care information at the top of this page for the numbers to call.
Please note that it may take up to thirty days for your choices regarding marketing contacts from us to become effective. If you are our customer, you will still receive billing and service related emails from us even if you choose not to receive marketing contacts.
What access do customers have to information about themselves?
Access through billing statements. Your monthly billing statement contains the primary name on your account, the services you subscribe to or use, and the amount billed. A paper billing statement may contain less detailed information about specific services or usage than information available online. Both may contain other information, such as regulatory notices and charges passed on to you from other service providers. If you find a mistake in the information we have or if you have any questions about your account, please call us. Please see the Customer Care information at the top of this page for the numbers to call.
Telephone and online access. We will discuss your account with you or with someone you authorize (once the caller is properly authenticated). Information may also be available to an authorized user through your online account profile or through interactive tools on our website such as “click to chat.” If you want to authorize someone to talk about your services or other account details, call us. Please see the Customer Care information at the top of this page for the numbers to call.
Releasing information upon written request. Upon your request and subject to proper authentication, we will disclose account information to third parties. Please see the Customer Care information at the top of this page for the numbers to call.
How does Convergence secure customer information?
Restricted access to information. Only Convergence employees, agents, service providers and other businesses we work and share information with and who have a legitimate business purpose are authorized to access customer information. This access is strictly defined (often involving password controlled access and other security controls) and subject to policies and contracts requiring confidential treatment of the information.
Securing sensitive information. We use secure technologies to transfer sensitive information and comply with a variety of industry standards, and federal and state laws regarding the protection of customer information.
Employee and vendor training. We require employees to protect customers’ information. We train our employees on those policies when they are hired, and we update that training periodically. When necessary, we train vendors on our policies as well.
Proactively protecting your own information. We encourage our customers to actively protect their personal information. Don’t give identifying information to strangers or others unless you’re certain they have a right to or a need for the information. Also, protect the security of personal information you transmit over home networks, wireless routers, Wi-Fi networks, and similar devices by using encryption and other techniques to prevent unauthorized interception.
If you think information about you or others has been disclosed without proper authorization, please contact us at support@Convergence.com, or write us at:
101 WEST BROADWAY
SAN DIEGO, CA 92101